What the new horizontal tax consolidation regime may mean for private equity sponsors, multinational groups, financial institutions (and everyone else…).
In June 2014, the European Court of Justice (ECJ) ruled that the...more

On July 8, the Right Honourable George Osborne MP, Chancellor of the Exchequer, introduced measures in his Summer Budget to abolish what is commonly known as the “base cost shift” as applied to sums received by individuals...more

The Chancellor of the Exchequer’s Summer Budget on 8th July introduced a series of unexpected tax changes affecting the private equity and investment management industry along with the promise of further changes to come....more

The French 3 Percent Distribution Tax: Claiming a Refund -
Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

The number of additional months of funding for transportation projects under a $8 billion bill introduced late last night in the House. Notably — as anyone on Sesame Street could tell you — the number 5 is not the same as the...more

The first fully Conservative Budget for 18 years, following the end of the Coalition as a result of the May general election, was anticipated to be a 'Big Budget' but in truth it was a mixed bag: the game changers are the...more

Over the past few months, several foreign portfolio investors registered in India have received notices from the Indian tax authorities demanding payment of Minimum Alternate Tax in respect of transactions which took place...more

Following the taxpayer’s victory in the recent Supreme Court decision of HMRC v Anson, UK resident members of Delaware LLCs may now be entitled to claim relief against their UK tax liabilities for US tax paid on their share...more

The UK Supreme Court delivered an unexpected final judgment on 1 July 2015 in the long-running case of Anson v Commissioners for Her Majesty’s Revenue & Customs [2015] UKSC 44. Reversing the decisions of the Upper Tribunal...more

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

When funds are moved through a corporate group, whether to fund an acquisition or the working capital needs of an affiliate, the transfers may be recorded as book-entry advances and not documented or documented at a later...more

The Cayman Islands has long been the most prominent offshore jurisdiction through which to structure offshore private equity and venture capital funds.
Why the Cayman Islands?
The attractions for international...more

The European Commission’s Action Plan for Fair and Efficient Corporate Taxation in the EU sets out proposals aimed at making corporate taxation in the EU more transparent and efficient, by reforming a system which is seen as...more

While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more

The eagerly anticipated Irish Collective Asset-management Vehicles Act 2015 (the “ICAV Act”) was signed into law in March 2015 and the first Irish Collective Asset-management Vehicles (“ICAVs”) have been authorised by the...more

The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners...more

In February, the New York Times published an 8,000-word investigation into wealthy foreigners buying New York City real estate and taking advantage of U.S. laws that allow them to set up shell companies in order to obscure...more

If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including...more

In one corner, we have Code §368(a)(1)(F) which generally allows for a corporation to move from one jurisdiction to another without triggering gain or other immediate adverse income tax consequences. The purpose is to allow...more

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules.
On June 3, 2015, the US Department of the...more

On May 27, a London jury found three employees of Swift Technical Solutions Ltd (Swift) not guilty of corruption charges in connection with alleged corrupt payments to tax officials in Nigeria. The SFO announced the verdict...more

Going international is a complicated undertaking. The steps required will depend on your specific situation and concerns. The following outlines, in very general terms, some of the issues you must consider as you begin to...more

Any U.S. person with a foreign affiliate is required to file the 2014 Form BE-10, Benchmark Survey of U.S. Direct Investment Abroad by June 30, 2015 or face civil penalties between $2,500 and $25,000. Further, a willful...more

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